NHTSA
Action Plan for 15-Passenger Van Safety
Introduction
There is growing
concern regarding the crash involvement and safety of 15-passenger
vans and the resulting injuries and fatalities. There were approximately
500,000 registered 15-passenger vans in 2001, an increase of
over 280 percent since 1990. Between 1990 and 2001, 1,441 15-passenger
vans were involved in fatal crashes that resulted in 1,003 fatalities.
Six hundred and one (601) of the crashes were single vehicle
crashes, of which 316 rolled over. Heavily loaded 15-passenger
vans are particularly susceptible to rollover. Confounding this
problem, the rate of safety belt use among occupants of large
vans involved in fatal crashes is very low compared to other
types of vehicles. While this plan focuses on 15-passenger vans,
the actions identified also relate to 12-passenger vans which
are similar to vans configured for 15 passengers in terms of
design, handling characteristics, and safety problems. NHTSA
defines vehicles designed to carry more than 10 persons as buses
for purposes of the Federal Motor Vehicle Safety Standards (FMVSS).
Background
Crashes involving large vans, especially rollover crashes and
the resulting fatalities and injuries, have raised the level
of public and NHTSA attention to this issue. In 2001, 130 occupants
of 15-passenger vans died in crashes involving these vehicles.
Single vehicle crashes represented 42 percent of fatal crashes.
Eighty-seven percent of people who died in single vehicle rollovers
of these vehicles were not wearing safety belts. Between 1990
and 2001, 15-passenger vans represented .25 percent of the passenger
vehicle fleet, .26 percent of passenger vehicles involved in
fatal crashes, and .25 percent of all passenger vehicle occupant
deaths. During this time, 8 percent of belted occupants in these
vehicles in fatal single vehicle crashes were killed, compared
to 22 percent of unbelted occupants.
In October 2002, NHTSA management briefed staff from the Senate
Commerce, Science and Transportation Committee and staff from
the office of Senator Olympia Snowe (R-Maine) on NHTSA actions
pertinent to the safety of these vehicles in the areas of research
and consumer information. A rollover crash in Maine killed 14
occupants of a van in 2002. In March 2003, Senator Snowe introduced
S.717 to address 15-passenger van safety. A similar bill was
introduced in the House, H.R. 1641, by Representative Mark Udall.
Senator Snowe’s bill called on NHTSA to develop a dynamic test
to assess rollover risk for 15-passenger vans and to issue the
results as consumer information; to test these vehicles at
different loading levels as part of the New Car Assessment Program
(NCAP); to test stability control and other technologies to
assess effectiveness in reducing rollovers; and called on the
Federal Motor Carrier Safety Administration (FMCSA) to apply
Federal motor carrier safety regulations (FMCSR) to the commercial
operation of 15-passenger vans.
Since November 2002, the National Transportation Safety Board
(NTSB) has issued nine recommendations that relate to these
vehicles. These recommendations encompass vehicle countermeasures,
consumer information, driver programs, working with FMCSA, and
cooperating with outside groups to promote the safety of these
vehicles. This Plan references these recommendations under specific
action areas.
The Senate Commerce, Science and Transportation Committee is
considering provisions addressing these vehicles for the reauthorization
of the highway programs, namely: issue a final regulation no
later than September 30, 2004 to include 15-passenger vans
up to 10,000 pounds gross vehicle weight rating (GVWR) in the
dynamic rollover testing program mandated by the Transportation
Recall Enhancement, Accountability, and Documentation (TREAD)
Act; require 15-passenger vans up to 10,000 pounds GVWR to comply
with all existing and prospective FMVSS for occupant protection
and vehicle crash avoidance; by September 30, 2004 include vehicles
up to 10,000 GVWR in the NCAP rollover resistance test program,
at various load conditions; require the FMCSA to implement a
final rule requiring the application of the FMCSR to 15-passenger
vans used for commercial purposes; and require NHTSA to evaluate
and test, in conjunction with van manufacturers, the potential
of technological systems (particularly electronic stability
control (ESC) systems and rear-view mirror-based rollover warning
systems) to assist drivers in maintaining control of the vans.
NHTSA has initiated
actions in the past and is implementing new strategies to address
the safety of these vehicles. This Plan describes past, current,
and planned activities in the areas of Problem Identification,
Consumer Information and Education, Countermeasure Research,
and Vehicle Countermeasures.
NHTSA Actions and Plans
I. Problem Identification
Prior Research:
A 2001 NHTSA study included three different analyses addressing
whether 15-passenger vans, especially loaded 15-passenger vans,
are unusually susceptible to rollover. The results from State
Data System analyses indicated that the rollover propensity
for 15- passenger vans was slightly less than for the overall
light truck and van (LTV) group, that rollover propensity increases
with the occupancy level of the 15-passenger van, and that higher
occupancy levels caused crash severity to increase from property
damage only (PDO) to injury and fatal crashes. Analysis of state
data also found that rollover rates for 15-passenger vans did
not show any significant correlation to driver age and that
fatalities occurred disproportionately to rear seat occupants,
while injuries were proportional between front and rear seat
occupants. An assessment also was conducted comparing the static
stability factor (SSF) of a 15- passenger van to a 7-passenger
full size van and a minivan when lightly loaded (driver only)
and fully loaded to
GVWR. This analysis found that the SSF for all three vehicles
decreased (higher likelihood of rollover) when fully loaded.
Based on a limited number of crashes, heavily loaded 15- passenger
vans appear to have a higher rollover rate compared to when
these vehicles are lightly loaded (with fewer occupants).
The agency also performed computer modeling to assess the handling
of these vehicles. The modeling predicted understeer for 15-passenger
vans when lightly loaded, similar to minivan behavior. However,
when heavily loaded, it predicted understeer at low lateral
acceleration, but oversteer at higher lateral accelerations.
This transition to oversteer may pose safety problems for drivers
who are unfamiliar with this characteristic. Loading 15- passenger
vans to gross vehicle weight (GVW) also moved center of gravity
rearward, increasing vertical load on rear tires.
Current and Planned NHTSA analyses for problem identification:
Assessment of Crashes, Fatalities, and Injuries in 15-Passenger
Vans: The National Center for Statistics and Analysis (NCSA)
is updating the crash data analysis portion of the 2001 work.
The study is taking a comprehensive approach to analyzing the
safety of 15-passenger vans in recent crash data. The analysis
is evaluating the experience of 15-passenger vans in fatal crashes
as compared to other vehicle types and the experience of 15-passenger
vans in the State Data System. A report on these results will
be released in conjunction with a Consumer Advisory (See Consumer
Information section).
Complete analysis and agency review September
2003
Release report
October
2003
Survey Tire Pressure and Condition in the
12- and 15-Passenger Van Fleet and Analyze the Role of Tires
in Rollover Causation: As part of NHTSA’s development of
long-term performance requirements for tire pressure-monitoring
systems, NTSB recommends (August 2003) NHTSA adopt more stringent
detection standards than 25 or 30 percent below manufacturer-recommended
levels. This recommendation is based on the NTSB’s view that
pressures at those levels may have an adverse effect on the
handling of vehicles, such as 12- and 15-passenger vans. Work
is currently being conducted at the NHTSA Vehicle Research and
Test Center (VRTC) on the relationship of tire pressure in front
and rear tires, loading conditions, and handling for a 15-passenger
van (see Countermeasure Research section for detail). The agency
believes that more information is needed on the level of tire
pressure under-inflation and tire wear conditions for 15-passenger
vans in use for potential utilization in consumer information,
vehicle solutions, or other actions. To this end, NCSA will
conduct a study, based on methods used in a recent light vehicle
TPMS survey, to collect tire pressure and condition information
on this class of vehicle. In-house analysis also will be done
to examine the involvement of tires in rollover crash data.
In-house analysis of rollover crash data
and tires October 2003-January
2004
Complete tire pressure and condition survey
June 2004
Publish results of in-house analysis and survey
July 2004
Crash Mechanisms in 12- and 15-Passenger
Vans: More information is needed on what happens in crashes
involving these vehicles to help formulate potential vehicle
solutions. NHTSA crash data will be analyzed for information
on crash dynamics and injury mechanisms to inform decisions
on future actions.
Complete analysis
May 2004
Issue final report
June 2004
Assess the Definition and Classification
of this Vehicle Type: NTSB recommendation H-03-12 calls
for NHTSA, in cooperation with the FMCSA, to revise it’s definitions
of buses and commercial motor vehicles to apply consistently
to 12- and 15-passenger vans, taking into account the unique
operating characteristics and multiple functions of these vans.
NHTSA will cooperate with the FMCSA to revise its definitions
of buses that are used in interstate commerce. Both agencies
have assigned staff to work jointly in assessing the definitions
and how best to revise them. As an adjunct to this effort, an
analysis is planned to identify how this type of vehicle is
classified at the state and other jurisdictional levels. In
some cases, legal loopholes exist at the state level as a result
of classifying this type of vehicle as a bus (for example, exemption
from laws requiring use of child restraints). The output of
this analysis will be a list of the laws in the 50 states and
the District of Columbia that apply to this class of vehicle
and an assessment of the implications of these classifications
and laws on safety and a recommendation on how to proceed regarding
the development of uniform classification.
Complete study of state laws
April 2004
Issue final report
July 2004
Develop Information on the Ownership and
Usage of These Vehicles: Little is known about the approximately
500,000 vehicles of this type on the road, namely: who owns
them, who drives them, who uses them, for what purposes, their
frequency of use and whether safety belt use is higher or lower
with certain populations using this type of vehicle. NHTSA will
work with the American Association of Motor Vehicle Administrators
to determine if this information is available and not cost-prohibitive
to collect, as well as not in violation of privacy regulations.
In addition, information is needed on whether certain groups
(e.g., church, school, college, military, government, migrant
workers) are over or under-represented in crashes, injuries
and fatalities, especially in rollover crashes. This information
is needed in order to develop effective, targeted programs for
the relevant groups.
Complete
study
May 2004
Issue final report
July 2004
II. Consumer Information and
Education
Prior NHTSA Actions:
In April 2001, NHTSA issued a Research Note
and Consumer Advisory on 15-passenger van safety. The Research
Note covered the findings from the three part study conducted
by NHTSA (described in the Problem Identification section above).
The April 2001 Consumer Advisory informed the public that 15-passenger
vans should be operated by "experienced drivers" and noted that
a commercial driver’s license (CDL) is required to transport
16 or more people for commercial purposes. The Consumer Advisory
urged drivers to be familiar with the handling of fully loaded
15-passenger vans and urged institutions using 15-passenger
vans to require safety belt use at all times. In April 2002,
Dr. Runge reissued the 2001 Consumer Advisory at a news conference,
together with a flyer on 15-passenger van safety and a hang
tag to leave in 15-passenger vans that provided information
on the risk of rollover, tips for preventing rollover, buckling
up for safety and other tips for safe driving.
NHTSA’s policy is that pre-school and school
aged children should not be transported in these vehicles due
to safety concerns. In February 2002, just prior to NHTSA reissuing
the 2001 Consumer Advisory on 15-passenger van safety, NHTSA
sent a letter to each state president of the National Automobile
Dealers Association (NADA) reminding them of the Federal requirements
that apply to the sale or lease of vehicles used to transport
students to and from school and school-related activities. Letters
were also sent to state directors of pupil transportation as
well as to independent education groups outlining these Federal
requirements and NHTSA’s school bus safety standards. Similar
letters were sent to these groups in 1995 and 1997. Enclosed
with each of these letters was a fact sheet, "School Buses:
The Safest Choice for Student Transportation," explaining why
school buses are safer than 15-passenger vans for transporting
children. In August 2003, NHTSA issued new regulations amending
the school bus safety rules to encourage churches and other
groups to use buses instead of vans.
In November
2002, NHTSA, in partnership with the Health Resources and Services
Administration (HRSA) and the American Academy of Pediatrics
(AAP), announced a training program for child care providers
called Moving Kids Safely in Child Care. The two-day
training program educates child care providers about how to
safely transport children using the appropriate child restraints
for their ages as well as the benefits of transporting children
in school buses versus 15-passenger vans. This training program
is available through the state highway safety offices. To date,
over 2,900 child care providers across the country have completed
this training program.
Current and Planned Actions:
Consumer Information Advisory: Develop
Consumer/Media Advisory to inform the public that only "experienced"
drivers should operate 15-passenger vans and the importance
of safety belt use in all vehicles, especially 15-passenger
vans.
Issue Consumer/Media Advisory
October 2003
Revise Consumer Information Hangtag:
The Reducing the Risk of Rollover Crashes in 15-Passenger
Vans hangtag will be modified to summarize messages that
will be simple and straightforward (checklist format). This
revised hangtag will be distributed to our partners, including
AAA, Automotive Service of Excellence (ASE), Jiffy Lube, National
Association of Independent Insurers (NAII), and National Credit
Unions, among others. This can be done quickly, prior to development
of a vehicle label. (See Vehicle Countermeasures)
Issue revised hangtag
October 2003 (in conjunction
with the
Consumer Advisory and
Research Report)
Disseminate Warning Messages: Include
cautionary warning messages to users of 15-passenger vans on
the safety issues regarding these vehicles and the importance
of wearing safety belts, in existing and future communications
resources. Methods of distribution include a CART partnership
distribution of our materials at its races and existing NHTSA
mechanisms, namely, the NHTSA Hotline and the new NHTSA web
site on Rollover at http://www.nhtsa.dot.gov/hot/rollover/Index.html.
Add information to new Rollover section
of the NHTSA website October 2003
Outreach Actions: Actions include
two initiative areas.
Technical Assistance: Include 15-passenger
van safety information in relevant Departmental efforts and
regional outreach activities. NHTSA attends trade shows, conventions,
etc., throughout the year, and these events offer opportunities
to reach a varied audience and promote vehicle safety messages.
Utilize existing partnerships with National Collegiate Athletic
Association (NCAA) and umbrella church and youth
organizations.
- NHTSA has existing partnerships
with many organizations to implement traffic safety and injury
control programs. Throughout FY 2004, NHTSA will work with the
following organizations to provide technical assistance for
their efforts to develop programs and policies to address 15-passenger
van safety and provide them with NHTSA materials to disseminate
throughout their organization:
- National
Automobile Dealers Association (NADA)
- Auto
manufacturers
- Governors
Highway Safety Association
- Education
and school transportation organizations
- Branches
of the military (they have expressed interest in developing
a training program for their drivers)
- Religious
groups
- Colleges
and universities
- Rental
van fleets
- YMCA
and summer camp organizations
- Organizations
that focus on migrant workers
- Head
Start and day care provider organizations
Training and Education: The focus
of NHTSA’s driver training program is on novice teenage drivers.
NHTSA has a cooperative agreement with the highway safety center
at Indiana University of Pennsylvania to develop novice driver
training programs and driver education curriculums. Commercial
uses of 15-passenger vans typically involve experienced drivers,
and, because of liability issues within this industry, many
commercial operators require their drivers to take training.
A majority of the highly publicized crashes involving 15-passenger
vans have involved inexperienced drivers for private organizations
such as churches and YMCAs. Because of the infrequent use of
these vehicles for these purposes, drivers are less likely to
have taken formal training. In addition, many of these organizations
operate programs with volunteers and with limited budgets.
Several program efforts are being planned including
development of educational materials focused on the safe use
of 15-passenger vans; a 15 minute video showing the risks of
and tips for reducing the risks associated with driving a 15-passenger
van including, but not limited to, operating in a heavily loaded
condition, emergency braking, tire-blowouts, tire pressure and
maintenance and the importance of buckling up; and, as part
of the Interagency Agreement with OSHA, NHTSA will include a
section on 15-passenger van safety in a traffic safety handbook
for employers.
Develop
15-passenger van section for handbook
December 2003
Develop video
April 2004
Develop educational materials
October 2004
III. Countermeasure Research
Prior Research
NHTSA’s
April 2001 Research Note & paper is described under Problem
Identification.
Current and Planned Research
In response to the NTSB recommendation on tire
pressure monitoring systems with regard to the potentially adverse
effect marginally low tire pressures can have on 15-passenger
van handling (H-03-17), NHTSA is adding tests for these vehicles
to a tire testing program at VRTC to see the effect on vehicle
handling from different front and rear tire pressures.
Complete testing
October 2003
Final Report
January 2004
Dynamic Rollover Resistance and Handling
Evaluation of 15-Passenger Vans: Testing is underway at
VRTC to see whether it is appropriate to use the rollover resistance
maneuvers developed for the NCAP rollover ratings program to
assess the dynamic rollover resistance of two 15-passenger vans.
Specifically, the Slowly Increasing Steer, NHTSA J-Turn, and
NHTSA fishhook maneuvers will be used. The minimum maneuver
entrance speed capable of producing two-wheel lift, the maximum
lateral acceleration, and understeer gradient of each vehicle,
under 3 load configurations (5, 10, and 15 occupants) will be
documented in a report. While NHTSA is not including these tests
as part of NCAP, their results will be posted on the NHTSA website.
Complete testing
November 2003
Final Report
February 2004
Evaluate Electronic Stability Control (ESC)
in 15-Passenger Vans: In November 2002 the NTSB recommended
that NHTSA "evaluate, in conjunction with the manufacturers
of 15-passenger vans, and test as appropriate, the potential
of technological systems, particularly electronic stability
control systems, to assist drivers in maintaining control of
15-passenger vans." NHTSA will evaluate the dynamic rollover
resistance of one 15-passenger van with enabled and disabled
stability control using J-Turn and fishhook rollover resistance
maneuvers. Only GM and Ford produce 15-passenger vans. At this
time, only GM intends to implement ESC on these vehicles. It
is anticipated ESC will be available on GM 15-passenger vans
in mid-to-late October 2003.
Complete testing
December 2003
Final Report
February 2004
IV. Vehicle Countermeasures
Current and Planned Actions:
Vehicle Labeling: Prior NHTSA consumer
research and information developed for the 2002 hangtag will
be used to develop a warning label that might be required for
new 15-passenger vans. Candidate information includes warnings
about loading, handling and proper tire pressure.
Evaluate previous work on rollover labels/investigate
feasibility of labels June 2004
FMVSS 208, Occupant Crash Protection:
Anton’s Law, signed into law in December 2002, requires lap
and shoulder belts (3-point belts) at all seating positions
(notably the center rear seat) for vehicles with a GVWR of 10,000
pound or less. 15-passenger vans have bench seats with seating
for three or four passengers, but usually only the outboard
seats have lap and shoulder belts. NHTSA published an NPRM on
August 6, 2003 that would require lap and shoulder belts in
rear center seats in all vehicles up to 10,000 pounds GVWR.
One practical way to install lap and shoulder belts in all 15-passenger
van seating positions (and to stiffen seat backs) might be to
use integrated seats. This activity relates to NTSB H-03-15.
Final rule
December 2004
FMVSS 214, Side Impact Protection: The
agency is planning to upgrade FMVSS No. 214. The proposed upgrade
will apply to all passenger cars, and trucks, buses and multipurpose
passenger vehicles with a GVWR of 10,000 pounds or less. Some
of NTSB’s concerns about additional head impact protection may
be addressed by this upgrade.
NPRM to upgrade FMVSS 214
May 2004
Part 571.3, Definitions: NHTSA is in
the process of revising the definition of "designated seating
position" to include a formula based on the width of a row of
seats. The agency is concerned that if occupants are too squeezed
together, they would not be able to access or use the shoulder
part of the 3-point belt. So as not to adversely impact big
van safety, NHTSA is considering whether to apply a different
formula to 12-15 passenger vans that would require more space
per position on seats designed to hold more than three passengers.
This would make it more likely that each passenger would be
able to use – and not just have – a safety belt.
NPRM
December 2003
FMVSS 216, Roof Crush Resistance: The
planned upgrade of this standard will expand its coverage to
vehicles up to 10,000 pounds GVWR (with certain exceptions).
This action relates to NTSB recommendation NTSB H-03-16. The
agency’s proposed upgrade will provide more uniform protection
for 15-passenger van occupants. Agency testing of 15-passenger
vans will test roof crush for the front seat occupant positions.
Testing at VRTC has shown that these vehicles barely pass the
current FMVSS 216 requirements and would require stronger roofs
to pass the upgraded requirements. In the upgrade currently
under development there are no plans to modify the test procedure
by moving the test plate toward the rear of the roof. It is
currently not clear whether there is a need to develop a test
for the rear positions from a safety problem perspective. Current
data analysis suggests that the problem of roof crush is largely
a front seating position problem in terms of roof contact and
that safety for occupants in rear seating positions is more
dependent on belt use/ejection. However, this problem will be
studied to determine if a modified test from FMVSS 220, School
Bus Rollover Protection is needed, which would test roof
strength for rear positions by applying horizontal forces.
Study of rear seating positions as part
of Crash Mechanisms in 12- and 15-Passenger
Vans (see Countermeasure Research)
February 2004
NPRM for FMVSS 216 upgrade
March 2004
Conclusions
NHTSA will pursue the actions included in this
plan within the parameters of available staff, resources, and
safety priorities. The recently published NHTSA Vehicle Safety
Rulemaking Priorities and Supporting Research, 2003-2006
(July 2003) describes our top vehicle safety priorities aimed
at reducing the greatest number of crashes, injuries, and fatalities
in the coming years.
